STOP THE FORMALDEHYDE INSANITY

Current edition brought to you by: FEMA Trailers

The furniture industry—along with many others— is under the gun!

Enforcement of rule starts But all the details have not yet So is CARB Enforcement of rule starts 1 April 2009 But all the details have not yet been worked out

Regulations

HCHO—CARCINOGENICITY EPA—“B1” Probable human carcinogen ACGIH—“A2” Suspected human carcinogen WHO (IARC)—“Group 1” Carcinogenic to humans

OCCUPATIONAL EXPOSURE STANDARDS HCHO OCCUPATIONAL EXPOSURE STANDARDS ACGIH TLV® 0.3 ppm (Ceiling) OSHA PEL 0.75 ppm (TWA) 2 ppm (Ceiling) NIOSH REL 0.016 ppm (TWA) 0.1 ppm (Ceiling)

According to renowned toxicologist However… According to renowned toxicologist Meryl H. Karol, Ph.D.

Testimony of Dr. Meryl H. Karol Professor Emerita, University of Pittsburgh Pittsburgh, Pennsylvania Before the U.S. House Committee on Science and Technology Subcommittee on Investigations and Oversight Hearing on “Toxic Trailers: Have the Centers for Disease Control Failed to Protect Public Health?” Tuesday April 1, 2008

“There is considerable controversy regarding the conclusion that formaldehyde causes cancer in humans.”

MEASURING FORMALDEHYDE

NIOSH ANALYTICAL METHODS

(1,8-dihydroxynaphthalene-3,6-disulfonic acid) Method 2016 most sensitive Silica gel/2,4-dinitrophenylhydrazine Method 2541 Sorbent tube/2-hydroxymethyl piperidine Method 3500 Impinger/chromotropic acid (1,8-dihydroxynaphthalene-3,6-disulfonic acid)

INSTRUMENTATION METHODS Practical and otherwise

Proton Transfer Reaction–Mass Spectrometry (PTR-MS) FTIR Semi-automated wet chemical methods Electrochemical (converted alcohol detectors) Interscan purpose-designed HCHO sensor

FLEC Field and Laboratory Emission Cell

FLEC is placed onto material to be tested such that the surface of the material effectively becomes one wall of a mini (≈ 35 ml volume) test chamber

A controlled flow of purified and humidified air enters the cell from a baffle around the perimeter of FLEC passing over the test material at flow rates simulating real-world conditions.

INTERSCAN PORTABLE ANALYZER

Direct-reading unit Integral pump Read formaldehyde level instantly

CARB has worked out a technique using the FLEC with the Interscan portable formaldehyde analyzer on raw board This correlates with chamber methods

BUT… Is FLEC/Interscan combination practical for field testing?

Probably not ASTM D 7143 – 05 Standard Practice for Emission Cells for the Determination of Volatile Organic Emissions from Indoor Materials/Products Has many provisions which would preclude its use for field testing

Such as… Temperature and humidity have to be controlled (23 ± 2°C and 50 ± 5% RH) If the indoor material under test is not homogeneous (for example, natural wood), repeat for multiple test specimens in order to establish a mean area specific emission rate. FLEC has to be flushed with clean, humidified air for approximately 15 minutes. Long sample equilibration time

Most practical field method would be to directly “sniff” the furniture piece with an Interscan analyzer

A suitable fudge factor would be built in to accommodate Empirically-derived boundary conditions would create a pass/fail HCHO value, based on testing at the furniture piece A suitable fudge factor would be built in to accommodate various environmental effects

Here’s the good news…

The Consumer Product Safety Improvement Act is jump-starting a grass roots backlash against excessive regulation Possibly the worst law passed in the last 50 years

industry should take advantage of this opportunity All over-regulated industry should take advantage of this opportunity

The American Home Furnishings Alliance Special thanks to… Bill Perdue and The American Home Furnishings Alliance